83 N.Y.2d 653 (1994)

A trial court does not err in excluding evidence offered solely to impeach a witness’s credibility on a collateral matter when the witness’s bias and interest have been exhaustively explored during cross-examination.

Summary

Kenneth Inniss was convicted of murder and weapon possession. The key witness against him, Richard Saunders, had a cooperation agreement with the prosecution. Inniss appealed, arguing that the trial court erred by refusing to admit testimony from Saunders’s alleged victim in a dismissed robbery case and the transcript of Saunders’s cooperation agreement. The Court of Appeals affirmed, holding that the evidence was offered only to impeach Saunders’s credibility on a collateral matter, and Saunders’s bias had already been thoroughly explored. The court also found that the refusal to give a specific “interested witness” charge was not reversible error because the jury was aware of Saunders’s potential bias.

Facts

Richard Saunders, awaiting trial on robbery charges, contacted authorities claiming knowledge of Brian Rich’s killer. Saunders testified that Inniss offered him $10,000 to kill Rich, which he declined. On August 3, 1986, Saunders witnessed Inniss shooting Rich with an Uzi. Saunders had a cooperation agreement with the District Attorney’s office, promising dismissal of his charges in exchange for truthful testimony. Saunders testified about incriminating conversations with Inniss before and after the murder. Forensic evidence supported Saunders’s account. Inniss presented an alibi defense but was convicted.

Procedural History

The trial court convicted Inniss. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.

Issue(s)

1. Whether the trial court erred in refusing to admit testimony of the complainant in Saunders’s dismissed robbery indictment and the transcript of the cooperation agreement between Saunders and the prosecution.
2. Whether the trial court erred in refusing to give an interested witness charge specifically regarding Saunders’s testimony.

Holding

1. No, because the evidence was offered solely to impeach Saunders’s credibility on a collateral matter, and Saunders’s bias and interest were exhaustively explored during cross-examination.
2. No, because the charge as a whole, including the instruction that the jury could consider the interest or bias of any witness, was sufficient to convey the need to scrutinize Saunders’s testimony with care.

Court’s Reasoning

The Court of Appeals reasoned that Inniss only sought to introduce the evidence to contradict Saunders’s denial of guilt in the dismissed robbery charges, which was a collateral matter. The court cited People v. Pavao, stating that the collateral impeachment rule bars the admission of evidence used to establish “perjury” on collateral issues. Furthermore, the court noted that the terms of the cooperation agreement and Saunders’s interest and bias were “exhaustive[ly]” explored on cross-examination, making the documentary evidence cumulative, citing People v. Chin. The Court also addressed the refusal to give an interested witness charge regarding Saunders’s testimony, finding that because Saunders’s bias and interest were heavily emphasized, the jury was sufficiently informed to scrutinize his testimony. The court stated that the jury “intensely scrutinized Saunders’ testimony,” and thus, the omission was not reversible error, citing People v. Warren. The court emphasized that the key issue was whether any benefit Saunders received affected the truthfulness of his testimony. Judge Smith dissented, arguing that the trial court failed to produce Brady and Rosario material by withholding the cooperation agreement and minutes from the proceeding dismissing the robbery charge. The dissent also argued that it was essential for the trial court to give more than the standard interested witness charge.